Declaration of Yolanda Huang #2

Case 3:18-cv-00050-JD Document 25 Filed 02/12/18 Page 1 of 7
LAW OFFICES OF YOLANDA HUANG

1
YOLANDA HUANG, SBN 104543
2 475 14th Street, Suite 500
Oakland, CA 94612
3 Telephone: (510) 329-2140
Facsimile: (510) 580-9410
4
5 DENNIS CUNNINGHAM, SBN 112910
115A Bartlett St.
6 San Francisco, CA 94110
7 Telephone: 415-285-8091
Facsimile: 415-285-8092
8
Attorneys for Plaintiffs
9
10 UNITED STATES DISTRICT COURT
11 FOR THE NORTHERN DISTRICT OF CALIFORNIA
12
13 JACLYN MOHRBACHER, ERIN ELLIS,
DOMINIQUE JACKSON, CHRISTINA
14 No. 3:18-cv-00050-JD
ZEPEDA, ALEXIS WAH, AND KELSEY
ERWIN, on behalf of themselves and others PLAINTIFFS’ REPLY TO DEFENDANTS’
15 similarly situated, OPPOSITION TP EMERGENCY
APPLICATION FOR ORDER TO SHOW
16 Plaintiffs, CAUSE
17 vs.
18
19 ALAMEDA COUNTY SHERIFF’S OFFICE, et
al.,
20 Defendants.
21
22 1. SUMMARY
23 Defendants cite no authority permitting defendants to hold plaintiff Christina Zepeda in

excess of two court days without taking her before a magistrate. Defendants held Christina
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Zepeda for four (4) court days for a total of (7) calendar days before releasing her at 1:30 a.m. the
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morning on February 6, 2018; without charges
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Defendants demonstrate no probable cause for the traffic stop and subsequent arrest of
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Christina Zepeda, and no exigent circumstances for the warrantless entry, with guns drawn, use of
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Page 1 of 7
Mohrbacher v. Alameda County Sheriff’s Office 3:18-cv-00050,

excessive force and subsequent arrests at 1286 Maddox Road, Hayward, California for the
1
misdemeanor violations of being under the influence (Health & Safety §11550)
2
The lack of probable cause for the stop, warrantless entries, and arrests underscores the
3
retaliatory nature of the Sheriff’s actions, and plaintiffs request that defendants be censured for
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violating the constitutional rights of plaintiff and her companions, and ordered to cease making
5 pretextual traffic stops of plaintiffs, to obey the law and cease warrantless entries without exigent
6 circumstances; and to cease holding individuals for longer than 2 court days without bringing an
7 individual before a magistrate.
8 2. STATEMENT OF FACTS
9 Defendants submitted the declaration of Shaun Corey who stated that he knew plaintiff
10 Christina Zepeda was prohibited from possessing firearms and ammunition. (Dec. S. Corey, ¶4)
Shaun Corey stated that he received information from “confidential informants” that there “had
11
been” firearms in 1286 Mattox Road, and that Christina Zepeda “was involved” in the street level
12
sale of narcotics. (Dec. S. Corey, ¶3) Corey’s declaration is silent on the informants’ reliability,
13
and silent on any corroboration.
14
Christine Zepeda and Robert Maddox were stopped before 3 p.m. on January 31, 2018.
15 (Dec. Justin Eaglin, P. 1; L. 26) The entry into 1286 Mattox Road, was shortly after 3 p.m., not
16 pursuant to a warrant. After the warrantless entry without exigent circumstances, a warrant was
17 applied for and signed at 9:50 p.m. by Judge Dorado. (Dec. S. Corey, Ex. A, p. 3) The warrant
18 was for methamphetamines and indicia related to methamphetamines. No affidavit supporting the
19 application for search warrant is attached.
20 Christina Zepeda was not detained at the apartment. She was detained several blocks
away, off Mission Boulevard following a traffic stop. (Dec. C. Haendel ¶9) Christopher Haendel
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stated that the traffic stop of Christina Zepeda was based upon the car’s lack of a front license
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plate. (Dec. C. Haendel ¶8) His declaration does not dispute plaintiff Zepeda’s declaration that
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the vehicle had temporary dealer plates. Christopher Haendel claims that he retrieved a scale with
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methamphetamine residue and a gun from the automobile. No police report is attached to either
25 the declaration of Shaum Corey or Christopher Haendel. No evidence receipt is attached to either
26 declaration.
27 Plaintiff Christine Zepeda and Robert Maddox both state that they are unaware of and did
28 not view the sheriff’s deputies retrieving either a gun or a scale from the car.
Page 2 of 7

Justin Eaglin’s states that he is a deputy probation officer, and at 3:02p.m. on January 31,
1
2018 he received a call from Christopher Haendel, informing him of Christina Zepeda’s arrest. He
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completed the Revocation Petition two days later on February 2, 2018 and then dispatched the
3
revocation petition to be calendared. Plaintiffs’ filed their Emergency Petition for an Order to
4
Show Cause on February 4, 2018. This Court signed the Order to Show Cause on February 5,
5 2018, and plaintiff Zepeda and Christopher Plascencia were released in the early morning hours of
6 February 6, 2018. Defendants’ petition was in transit for four (4) days, arriving on February 6,
7 2018, for processing after plaintiff Zepeda and Christopher Plascencia had been released.
8 Christopher Plascencia was contacted by Christina Zepeda after the press conference
9 because Christopher Plascencia suffered a significant loss with the death of his three month
10 pregnant girlfriend, who died in custody in Santa Rita Jail on February 11, 2017.
11 3. ARGUMENT
12
A. DEFENDANTS FAIL TO CITE ANY AUTHORITY TO JUSTIFY INCARCERATING
13 CHRISTINA ZEPEDA IN EXCESS OF TWO COURT DAYS WITHOUT CHARGES.
14 Defendants cite not a single statute and no caselaw authorizing them to hold plaintiff
15 Christina Zepeda in excess of the two court day limit specified in Cal. Penal Code §825.
16 Defendants held Christina for 4 court days, not releasing her until the early morning hours of
17 February 6, 2018. This conduct is clearly a violation of Ms. Zepeda’s right to a speedy trial, under
18 the 6th Amendment. Furthermore, defendants held Christopher Plascencia for the same amount of
time. It is likely and probable that but for plaintiff’s Emergency Petition, both Ms. Zepeda and
19
Mr. Plascencia would have been incarcerated for an even longer.
20
Justin Eaglin states that he does not even finish the Petition to Revoke until February 2,
21
2018, which was the deadline for bringing Ms. Zepeda before a magistrate. Cal. Penal Code §825
22
Obviously, defendants had no intention of complying with the 48 hour or two court day
23 requirement of Cal. Penal Code §825.
24 Defendants offer the excuse of a delay in the dispatch of the Petition to Revoke. However,
25 whether the Petition arrived on the following Monday or Tuesday, is not relevant, because the
26 deadline for complying with Cal. Penal Code §825 passed on Friday, before the Petition was even
27 dispatched. Nonetheless, even if the petition was completed in a timely fashion, a delay in
28 dispatch does not excuse violations of constitutional rights, just as the dog ate my homework, does
Page 3 of 7

not guarantee anything more than a failing grade. Ms. Zepeda has a right to be timely charged
1
and brought before a magistrate, and not be subject to the whims of dispatch.
2
3 B. DEFENDANTS’ ACTIONS ARE REPLETE WITH DELIBERATE, PURPOSEFUL
VIOLATIONS OF PLAINTIFF ZEPEDA AND HER COMPANION’S
4 CONSTITUTIONAL RIGHTS.
5 Defendants conduct, starting on January 31, 2018 was out of control and reprehensible.
6 From the pretextual traffic stop, to the warrantless entry of a residence, to the clearly deliberate
7 over long incarceration without charges, defendants’ conduct demonstrate a disregard for the law
8 and shameless disregard for constitutional rights.
9 1. The Traffic Stop Was PreTextual And Violated Ms. Zepeda’s 4th Amendment Rights.
10 A traffic stop is an investigatory detention, a “Terry stop”. Terry v. Ohio (1968) 392 US 1
A Terry stop is justified only if it is based on at least reasonable suspicion that the driver has violated
11
the Vehicle Code or some other law. “The touchstone of the Fourth Amendment is reasonableness.
12
[Citation.]” Florida v. Jimeno (1991) 500 U.S. 248, 250. The facts of the situation must warrant a
13
man of reasonable caution in the belief that the action taken was appropriate” Terry v. Ohio (1968)
14
392 US 1, 21.
15 "[I] a traffic-stop setting, the first Terry condition — a lawful investigatory stop — is met
16 whenever it is lawful for police to detain an automobile and its occupants pending inquiry into a
17 vehicular violation. Arizona v. Johnson (2009) 555 US 323, 327.
18 In the present case, both Shaun Corey and Christopher Haendel state that they made the traffic
19 stop based upon the lack of a front license plate. The lack of a license plate alone is not sufficient
20 justification for an investigatory detention. An automobile in California is required to have front and
rear license plates only if the State has in fact issued them. Cal. Vehicle Code §5200(a). In many
21
circumstances, particularly with new cars, temporary tags, or a temporary operating permit in the
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window indicates the vehicle is legal. Cal. Veh. Code §§4156, 5202. A visibly legal vehicle
23
provides no reasonable cause for a traffic stop. The California Supreme Court has held that an officer
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stopping a car that has no license plates, violated the driver’s 4th Amendment Rights, if the officer
25 saw a temporary operating permit affixed to the windshield or rear window. People v. Hernandez
26 (2008) 45 Cal. 4th 295, 298. Both Christina Zepeda and Robert Maddox state that the car did not
27 have license plates but had temporary dealer plates on the front and the back, and had a temporary
28 operating permit affixed to the windshield. All of which was clearly visible. A vehicle is being
Page 4 of 7

operated legally despite missing license plates if a valid temporary operating permit is correctly
1
displayed. People v. Dotson (App. 3 Dist. 2009) 101 Cal.Rptr.3d 897, 179 Cal.App.4th 1045, review
2
denied. There was no reasonable cause for defendants to stop plaintiff Zepeda’s car.
3
4 2. Search and Seizure of a Probationer With a Search Clause Still Requires Reasonable
Suspicion_____________________________________________________________
5
Shaun Corey’s response to Christina Zepeda’s question, “[w]hy are you pulling me over?”
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that her probation search clause permitted him to stop the car, indicates a disregard for the 4th
7
amendment. Even with a probation condition, police must have reasonable suspicion to justify a
8 search and seizure. Moreno v. Zaca 400 F.3d 1152 (9th Cir. 2005) “The Fourth Amendment by its
9 explicit terms applies to all persons, regardless of their status under the law.” Moreno v. Baca, 400
10 F.3d 1152, 1158 (9th Cir. 2005) And probationers and paroles are treated essentially the same for
11 the purpose of fourth Amendment analysis. United States v. Davis, 932 F.2d 752, 758 (9th
12 Cir.1991) Even with a probation search condition, an individual’s “agreement to submit to
13 warrantless searches cannot be said to reduce his privacy rights so severely as to make a
suspicionless search reasonable.” Moreno v. Baca, 400 F.3d 1152, 1160 (9th Cir. 2005)
14
The purpose of a traffic stop is to ascertain a violation of a traffic law. While the stated
15
reason was the licensure of the car, Shaun Corey indicated told Christina Zepeda that the traffic
16
stop was for the purpose of doing a probation search. Corey did not even ask to view the
17
automobile’s registration, but immediately placed both Ms. Zepeda and Mr. Maddox under arrest.
18 Therefore, it is clear, the traffic stop was pretextual for the search and arrests, and a clear violation
19 of Robert Maddox and Christina Zepeda’s 4th Amendment rights.
20
3. Defendants’ Warrantless Entry Into 1286 Maddox Road Was Unreasonable and
21 Unconstitutional___________________________________________________
22 Defendants entered 1286 Maddox Road without a warrant, and arrested everyone inside the
23 apartment. “It is a ‘basic principle of Fourth Amendment law’ that searches and seizures inside a
24 home without a warrant are presumptively unreasonable.” Payton v. New York, 445 U.S. 573, 586,
25 (1980) Warrantless entries require exigent circumstances. Payton v. New York, supra, 445 U.S., at
26 586. When the government's interest is only to arrest for a minor offense, that presumption of
unreasonableness is difficult to rebut, and the government usually should be allowed to make such
27
arrests only with a warrant issued upon probable cause by a neutral and detached magistrate.
28
Welsh v. Wisconsin, 466 U.S. 740, 750, (1984)
Page 5 of 7

Everyone inside the apartment was arrested for being under the influence (Health & Safety
1
Code 11550), a misdemeanor and cited and released (Jaleh Kanallis and Christina Jones) or
2
arrested and not cited (Christopher Plascencia).
3
Neither Shaun Corey nor Christopher Haendel articulate exigent circumstances for
4
approaching the apartment with guns drawn, demanding that the occupants of the apartment open
5 the “fucking” door. The only justification is provided by Shaun Corey who states:
6 “15. Due to our findings as a result of the traffic stop, as well as our previous knowledge
7 from this investigation, we returned to the apartment ….to contact any remaining subjects in the
8 apartment and conduct a related probation search.” (Dec. S. Corey, ¶15)
9 Furthermore, Corey’s declaration contains no indicia of the reliability of the informants’
10 information, and no corroboration of the informants’ information which would meet the
requirement of reasonableness to justify the entry. A mere conclusory statement provides
11
“virtually no basis at all for making a judgment regarding probable cause.” Illinois v. Gates, 462
12
U.S. 213, 239
13
The warrantless entry by defendants further underscores the little regard defendants have
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for the rights of others, the little regard defendants hold for the constitutional protections that
15 everyone should be shielded by, and the free-wheeling means by which defendants disregard laws
16 specifically designed to provide checks and balances on police abuses, while they arrest and
17 imprison others with a free hand.
18 /////
19 /////
20 /////
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Page 6 of 7

4. CONCLUSION
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Christina Zepeda is a whistleblower trying to shed light on the abuse and mistreatment of
2
the vulnerable pregnant women by the Alameda County Sheriff and his deputies. The
3
unreasonable and unconstitutional actions by Sheriff’s deputies must be checked. Plaintiffs
4
request that the Court firmly restrain defendants from any and all retaliation or other groundless
5 harassment, or extra legal activities in any form against plaintiffs in particular, or against pregnant
6 women or any women in the jail.
7 Dated: FEBRUARY 12, 2018 Respectfully submitted,
8 LAW OFFICE OF YOLANDA HUANG
9 /s/ Yolanda Huang______
YOLANDA HUANG
10
11
DENNIS CUNNINGHAM
12 /s/ Dennis Cunningham___
DENNIS CUNNINGHAM
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14 ATTORNEYS FOR PLAINTIFFS
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Page 7 of 7

Case 3:18-cv-00050-JD Document 25-1 Filed 02/12/18 Page 1 of 3

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Oakland, CA 94612
3 Telephone: (510) 329-2140
Facsimile: (510) 580-9410
4
115A Bartlett St.
7 Telephone: 415-285-8091
Facsimile: 415-285-8092
8
9
12
DOMINIQUE JACKSON, CHRISTINA No. 3:18-cv-00050-JD
14 ZEPEDA, ALEXIS WAH, AND KELSEY
ERWIN, on behalf of themselves and others
15 similarly situated, REPLY DECLARATION OF CHRISTINA
ZEPEDA IN SUPPORT OF PLAINTIFFS’
16 Plaintiffs, APPLICATION FOR ORDER TO SHOW
17 CAUSE FOR RELIEF FROM FALSE
vs.
ARREST, INTIMIDATION AND OTHER
18 HARASSMENT OF PLAINTIFFS BY
ALAMEDA COUNTY SHERIFF’S OFFICE, et DEFENDANT ALAMEDA COUNTY
19
al., SHERIFFS’ DEPUTIES
20 Defendants.
21 I, CHRISTINA ZEPEDA, declare as follows:
22 1. I make this declaration of my own knowledge and if called to testify, I can and will testify as
23 stated herein.
24 2. As I pulled out of the driveway at 1286 Maddox Road, I prepared to turn right. I could see
25 the Sheriff’s SUV parked uphill from the driveway entrance. The time was just before 3 p.m.
26 It was a bright, clear, sunny day. There were dealer ‘s temporary tags on the front and the
back of the car. The car’s permit was taped to the windshield.
27
3. Immediately, the sheriff’s SUV followed and and stopped me less than one block later. When
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I was stopped, I specifically asked the officer, whom I assume was Christopher Haendel,
Page 1 of 3
Mohrbacher v. Alameda County Sheriff’s Office, Dec. C. Zepeda In Support Application for OSC
“Why are you pulling me over?” and he responded, “Christina Zepeda and Robert Maddox,
1
you are on probation and both of you have a search clause.”
2
4. I then responded, “That’s not a reason to stop me.”
3
5. Christopher Haendel responded, “That’s enough of a reason,” and told me to get out of the
4
car, handcuffed and placed into the back of a sheriff’s car. He never asked to see the
5 registration or insurance on the car. He never asked to see my driver’s license.
6 6. Later, when he was writing up the police report he stated that he pulled me over for driving a
7 vehicle without a license plate. I told him that he should correct that statement, because that
8 was a false statement. The car had dealer plates.
9 7. I have reviewed Shaun Corey and Christopher Haendel’s declaration. I read where they
10 claimed to have found a gun in the trunk of the car. I did not see Christopher Haendel find a
gun in the trunk of the car. Mr. Haendel did not inform me that he had found a gun in the
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trunk of the car. No one made that statement to me. And if there was a gun found, that gun
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would not have my fingerprints on it, nor any DNA connected to me, because I had no
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knowledge of a gun, nor any contact with any gun. I merely borrowed the car in order to go
14
buy some food. I had been driving the car for about a block when the Sheriff’s deputies
15 pulled me over. Prior to that, I had only been a passenger in the car.
16 8. Regarding any scale found in the car, I did not see Christopher Haendel find a scale in the
17 car. Mr. Haendel did not inform me that he had found a scale in the car. And if there was a
18 scale found, that scale would not have my fingerprints on it, nor any DNA connected to me,
19 because I had no knowledge of a scale, nor any contact with any scale.
20 9. I was then taken to Santa Rita Jail and held for six (6) days. I was released Tuesday, February
6, 2018 at 1:30 a.m. At that hour there is no public transportation. BART is not running.
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There are no buses. The Sheriff had confiscated my phone so I had no way to make even a
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phone call. I was wearing a tank top because I had been arrested on a warm afternoon and
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had to walk and walk until finally I came upon a business that was open so I could call my
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son to ask him to come pick me up.
25 10. The Alameda County Sheriff never gave me an official reason why I was in jail nor stated
26 what charges they were leveling against me.
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Page 2 of 3
I declare under penalty of perjury that the foregoing is true and correct. Executed in Oakland,
1
California.
2
Dated: Jan. 11, 2018 CHRISTINA ZEPEDA
3
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5 ____/s/ Christina Zepeda__________
CHRISTINA ZEPEDA
6
7
8
Under N.D. Cal. Local Rule 5-1(i)(3), I attest that I obtained concurrence in the filing of this
9 document from Christina Zepeda on January 3, 2018.
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By: __/s/ Yolanda Huang___________
11 YOLANDA HUANG
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Page 3 of 3

1
Oakland, CA 94612
3 Telephone: (510) 329-2140
Facsimile: (510) 580-9410
4
115A Bartlett St.
7 Telephone: 415-285-8091
Facsimile: 415-285-8092
8
9
12
15 similarly situated, REPLY DECLARATION OF ROBERT
MADDOX IN SUPPORT OF PLAINTIFFS’
vs.
19
20 Defendants.
21 I, ROBERT MADDOX, declare as follows:
23 stated herein.
24 2. I was in the car with Christina Zepeda on January 31, 2018 when we were stopped and then
25 arrested by Alameda County Sheriff Deputies. The first deputy who stopped us was dressed
26 in a black jumpsuit, with a ball cap; an outfit I identify as worn by SWAT teams.
3. After we were stopped, I was pulled out of the car and handcuffed. One of the officers put
27
two fingers on the inside of my wrist, and then examined my pupils. He asked if I was high,
28
and I responded, No. He then asked me if I was on heroin, and I said, No. He then asked me
Page 1 of 4
Mohrbacher v. Alameda County Sheriff’s Office, Dec. R. Maddox In Support Application for OSC
to close my eyes and count to thirty. I was able to do so. Four times, the sheriff’s deputy
1
asked me to close my eyes and count to thirty. Four times I was able to count to thirty. I was
2
then arrested and taken to Santa Rita Jail and the cited and released around 11:30 that
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evening. While I was not under the influence, I was cited for being under the influence
4
(Health & Safety Code § 11550(A)), a misdemeanor. Attached as Exhibit A is a true and
5 correct copy of the citation I received.
6 4. I did not see a deputy find a gun in the trunk of the car. No deputy stated that he had found a
7 gun in the car. And if there was a gun found, that gun would not have my fingerprints on it,
8 nor any DNA connected to me, because I had no knowledge of a gun, nor any contact with
9 any gun. I was with Christina the entire time on January 31, 2018, and I did not see Christina
10 Zepeda with or handle a gun, ammunition, or a scale.

5. Regarding any scale found in the car, I did not see the deputy find a scale in the car, and if
11
there was a scale found, that scale would not have my fingerprints on it, nor any DNA
12
connected to me, because I had no knowledge of a scale, nor any contact with any scale.
13
6. When I was stopped, I heard Christina ask why she was pulled over, and I heard the sheriff’s
14
deputy respond, “Christina Zepeda and Robert Maddox, you are on probation and both of you
15 have a search clause.”
16 7. Christina then said, “That’s not a reason to stop me.”
17 8. The sheriff’s deputy said, “That’s enough of a reason,” and told Christina to get out of the
18 car, where she was handcuffed and placed into the back of a sheriff’s car. The sheriff’s
19 deputies never examined Christina’s pupils or ask her to close her eyes and count to thirty.
20 The Sheriff never asked to see the registration or insurance on the vehicle.
9. I read Christopher Haendel and Shaun Corey’s declarations where they claimed that the car
21
lacked a front license plate. The car did not have license plates because it was a new car.
22
The car had dealer temporary registration, on the front and the back, clearly visible.
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I declare under penalty of perjury that the foregoing is true and correct. Executed in Oakland,
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California.
25 Dated: Jan. 11, 2018 ROBERT MADDOX
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____/s/ Robert Maddox__________
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ROBERT MADDOX
Page 2 of 4
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2 document from Robert Maddox on January 11, 2018, in Oakland, California.
3 By: __/s/ Yolanda Huang___________

YOLANDA HUANG
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EXHIBIT A
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1
Oakland, CA 94612
3 Telephone: (510) 329-2140
Facsimile: (510) 580-9410
4
115A Bartlett St.
7 Telephone: 415-285-8091
Facsimile: 415-285-8092
8
9
12
15 similarly situated, REPLY DECLARATION OF CHRISTOPHER
PLASCENCIA IN SUPPORT OF PLAINTIFFS’
vs.
19
20 Defendants.
21 I, CHRISTOPHER PLASCENCIA, declare as follows:
23 stated herein.
24 2. On January 31, 2018, Christina Zepeda came over to my apartment to tell me about the press
25 conference she had just participated in. Christina calls me “brother”, but we are not blood
26 relations, but good friends. Christina knows that the treatment of pregnant women in Santa
Rita is of concern to me, because my girlfriend of ten years, Christina Lamendola died last
27
year while she was three months pregnant with our baby, during her incarceration in Santa
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Rita. The one year anniversary of their deaths is today, February 11, 2018.
Page 1 of 2
Mohrbacher v. Alameda County Sheriff’s Office, Dec. C. Plascencia In Support Application for OSC
3. After she visited for a while, Christina asked if I would drive her to Hayward. I said, that I
1
would, because I could stop at a friend, Jaleh Kanellis’ apartment to take a shower. This is
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because the shower at my apartment was not working that day, and being repaired. So, I
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packed a duffle bag with clean clothes and toiletries, and all three of us, myself, Christina
4
Zepeda and Robert Maddox, drove to Hayward.
5 4. Christina dropped me off, and then left with Robert to go get some food. I jumped into the
6 shower, and as I was getting out of the shower, I heard someone pound on the door. I thought
7 it was Christina returning from getting some food. As I went to the front door, I could see
8 through the window that a white male wearing black, a bulletproof vest, and a tight fitting cap
9 on, kneeling on one knee was pointing a gun at me through the window. This man was
10 screaming, “This is the Sheriff. Open the fucking door.”

5. I said, I wasn’t dressed, that it was not my house and I wasn’t going to open the door. I then
11
ran into the back of the apartment to get dressed.
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6. I barely got my pants and shirt on. Very quickly, the Sheriff deputies were swarming in the
13
house, guns drawn and dragging us out onto the porch. They threw me down on the ground,
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face first, and someone put his foot on the back of my neck. I was very concerned that I was
15 going to be shot or seriously hurt.
16 7. The Sheriff’s deputies asked me repeatedly if I was high or on drugs, and I told them I don’t
17 do drugs. I was arrested and taken to Santa Rita. I was released six (6) days later on February
18 6, 2018 around 12:30 a.m., without charges.
19 I declare under penalty of perjury that the foregoing is true and correct. Executed in Oakland,
20 California.
Dated: Jan. 11, 2018 CHRISTOPHER PLASCENCIA
21
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23 ____/s/ Christopher Plascencia________
24
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26 document from Christopher Plascencia on January 11, 2018, in Oakland, California.
27
By: __/s/ Yolanda Huang___________
28 YOLANDA HUANG
Page 2 of 2
Mohrbacher v. Alameda County Sheriff’s Office, Dec. C. Plascencia In Support Application for OSC

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Case 3:18-cv-00050-JD Document 25 Filed 02/12/18 Page 1 of 7

LAW OFFICES OF YOLANDA HUANG

23 Defendants cite no authority permitting defendants to hold plaintiff Christina Zepeda in

Mohrbacher v. Alameda County Sheriff’s Office 3:18-cv-00050,

Mohrbacher v. Alameda County Sheriff’s Office 3:18-cv-00050,

Mohrbacher v. Alameda County Sheriff’s Office 3:18-cv-00050,

Mohrbacher v. Alameda County Sheriff’s Office 3:18-cv-00050,

Mohrbacher v. Alameda County Sheriff’s Office 3:18-cv-00050,

Mohrbacher v. Alameda County Sheriff’s Office 3:18-cv-00050,

Mohrbacher v. Alameda County Sheriff’s Office 3:18-cv-00050,

LAW OFFICES OF YOLANDA HUANG

LAW OFFICES OF YOLANDA HUANG

10 Zepeda with or handle a gun, ammunition, or a scale.

3 By: /s/ Yolanda Huang_________

LAW OFFICES OF YOLANDA HUANG

10 screaming, “This is the Sheriff. Open the fucking door.”

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